DTE Energy Company One Energy Plaza, 688 WCB Detroit, MI October 21, 2016

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1 DTE Energy Company One Energy Plaza, WCB Detroit, MI - Andrea Hayden ( - haydena@dteenergy.com October, 0 Ms. Kavita Kale Executive Secretary Michigan Public Service Commission 0 West Saginaw Highway Lansing, MI RE: Carol Brooks v DTE Energy Company MPSC Case No: U-0 Dear Ms. Kale: Attached for filing in the above referenced matter is DTE Electric Company s Supplemental Direct Testimony of Witnesses, Ebony Reid, Joanna Adkins, Shannon Robinson and James Skotzke and Supplemental Direct Exhibit of Shannon Robinson. Also attached is Proof of Service. Very truly yours, AH/lah Enclosures c: Service List Andrea Hayden

2 STATE OF MICHIGAN BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION In the matter of the Complaint of CAROL BROOKS against DTE ENERGY COMPANY Case No: U-0 SUPPLEMENTAL DIRECT TESTIMONY OF EBONY REID

3 DTE ELECTRIC COMPANY SUPPLEMENTAL DIRECT TESTIMONY OF EBONY REID Q. What is your name and business address? A. Ebony J Reid. I currently work at One Energy Plaza, 0 WCB, Detroit, MI. Q. Have you previously filed testimony in this Case? A. Yes. I filed direct testimony on June, 0 to address the claims made in the Complainant s First Amended Complaint. 0 Q. What is the Purpose of your supplemental testimony? A. The purpose of my supplemental direct testimony is to respond to new allegations raised by Complainant in her Second Amended Complaint regarding payment accomodations. Q. In her Second Amended Complaint, Carol Brooks alleges that DTE Electric did not offer her a reasonable payment arrangement for the unauthorized usage at the first floor of the Monica Property. When you met with Carol Brooks on December, 0, did you offer her a payment plan for the unauthorized usage recorded at the Monica Property? A. No, I did not. 0 Q. Why not? A. DTE Electric does not offer payment arrangements in cases of unauthorized usage for several reasons. First, there was no outstanding bill at the time to offer a payment plan to Carol Brooks. Second, the person with the unauthorized usage is not provided a physical bill until they are ready to pay to avoid instances where the person would a utilize the bill to declare bankruptcy, or b take the bill to agencies

4 E. REID Line U-0 such as the Michigan Department of Health and Human Services ( MDHHS and try to get them to pay. Agencies do not pay for unauthorized usage though, so when the agency goes through its auditing process and determines that a payment was made on unauthorized usage charges, the payment is retracted. Meanwhile, the customer has fraudulently had service restored and the Company is left with unpaid amounts for unauthorized usage. Q. Does this complete your direct testimony? A. Yes, it does.

5 STATE OF MICHIGAN BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION In the matter of the Complaint of CAROL BROOKS against DTE ENERGY COMPANY Case No: U-0 SUPPLEMENTAL DIRECT TESTIMONY OF JOANNA ADKINS

6 DTE ELECTRIC COMPANY SUPPLEMENTAL DIRECT TESTIMONY OF JOANNA ADKINS Q. What is your name and business address? A. Joanna Adkins, One Energy Plaza 0 WCB Detroit, MI. Q. On whose behalf are you testifying? A. DTE Electric Company ( DTE Electric or Company, Q. Have you previously filed testimony in this Case? A. Yes. I filed direct testimony on June, 0 to address the claims made in the Complainant s First Amended Complaint. 0 Q. What is the Purpose of your supplemental testimony? A. The purpose of my supplemental direct testimony is to respond to new allegations raised by Complainant in her Second Amended Complaint regarding payment accomodations. 0 Q. In her Second Amended Complaint, Carol Brooks alleges that DTE Electric did not offer her a reasonable payment arrangement for the unauthorized usage at the first floor of the Monica Property. When you met with Carol Brooks on December, 0, did you offer her a payment plan for the unauthorized usage recorded at the Monica Property? A. Q. Why not? A. A person must be an active customer of DTE Electric to be offered a payment plan.

7 J. ADKINS Line U-0 In cases of unauthorized usage, there is no active customer account. In this particular case, there was no active electric agreement for the first floor of the Monica Property and the account was coded as having unauthorized usage, so I did not offer Carol Brooks a payment plan. Furthermore, income is not taken into account in cases of unauthorized usage. Q. Does this complete your direct testimony? A. Yes, it does. 0

8 STATE OF MICHIGAN BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION In the matter of the Complaint of CAROL BROOKS against DTE ENERGY COMPANY Case No: U-0 SUPPLEMEN TAL DIRECT TESTIMONY OF SHANNON ROBINSON

9 DTE ELECTRIC COMPANY SUPPLEMENTAL DIRECT TESTIMONY OF SHANNON ROBINSON Q. What is your name and business address? A. My name is Shannon Robinson and my business address is One Energy Plaza, Detroit, MI. Q. On whose behalf are you testifying? A. I am testifying on behalf of DTE Electric Company ( DTE Electric or Company. 0 Q. Have you previously filed testimony in this Case? A. Yes. I filed direct testimony on June, 0 to address the claims made in the Complainant s First Amended Complaint. Q. What is the Purpose of your supplemental testimony? A. The purpose of my supplemental direct testimony is to respond to new allegations raised by Complainant in her Second Amended Complaint. Q. Are you sponsoring any additional exhibits with you supplemental direct testimony? A. Yes. I am sponsoring the following exhibits: 0 Exhibit R- Michigan Department of Human Health and Services Contact Note Q. Is this document generated and maintained in DTE Electric s regular course of A. Yes. business?

10 S. ROBINSON Line U-0 Q. Are you familiar with the claims in the Complainant s Second Amended Complaint? A. Yes, I am. Q. In your direct testimony, you sponsored Exhibit R- which included an August, 00 bill and shutoff notice to Ms. Brooks, is that correct? A. Yes, that is correct. 0 0 Q. In Paragraph s and of Complainant s Second Amended Complaint, she states that the August, 00 Bill (the 00 Bill lists September, 00 as the deadline for payment and no other dates for payment are provided. Is that correct? A. The 00 Bill listed September, 00 as the due date for the current charges. However, the past due amounts listed on the bill were due immediately. The shutoff notice on page of the 00 Bill states that if no date is indicated for payment of past due amounts, service is subject to immediate shutoff. There is no due date listed on the 00 Bill for past due amounts, therefore, they were due immediately. For comparison, the June, 00 bill included in Exhibit R- shows the due date for past due amounts in red as well as the due date for current charges in black. The 00 Bill also advised that the account remained in shutoff status because of the past due balance. Q. Paragraph of Complainant s Second Amended Complaint alleges that there were two different amounts to avoid shutoff. How much did the 00 Bill

11 S. ROBINSON Line U-0 require Complainant to pay to avoid shutoff? A. The 00 Bill required the Complainant to pay $. to avoid shutoff. A second amount to avoid shutoff of $0.0 was also listed. The $0.0 amount was the remaining past due balance after invoices in the amount of $. were cancelled due to being estimates. The important information section of the bill listed the past due amounts for electric service as $0. and gas service as $ Q. Did the Michigan Department of Health and Human Services (MDHHS contact DTE Electric to inquire about the status of Complainant s bill. A. MDHHS contacted DTE Electric to inquire about the status of the Complainant s bill on August, 00. The contact was made using the Online Resources for Agencies (ORA online website. The contact was only a general inquiry and there was no commitment to pay on the Complainant s account made by the agency representative. 0 Q. What is the difference between a commitment and an inquiry? A. An inquiry is when the agency pulls up the customer account to view pertinent information things like payment history, account status, and billing information. A commitment is a promise to pay the customer s bill and automatically generates a 0-day hold on the account to prevent interruption of service while payment is in process. In general, there is no hold placed on a customer s account when an agency simply makes an inquiry. In certain circumstances, a 0-day hold may be placed on an account after an inquiry, but this is case specific and this capability did not exist in 00.

12 S. ROBINSON Line U-0 Q. Does DTE Electric typically contact customers after their service has been shutoff? A. No, not typically, however, the Company may contact a customer after shutoff in an attempt to collect an outstanding debt. 0 Q. Complainant alleges in Count VI of her Second Amended Complaint that her service was involuntarily shutoff, therefore, she should have been contacted prior to disconnecting service at the first floor of the Monica Property on January, 0, is this accurate? A. Shutoff of service or unauthorized usage is not considered an involuntary shutoff, therefore, no attempts were made to contact someone at the first floor of the Monica Property. In cases of unauthorized usage, there is no active customer account, so no shutoff notice is required. 0 Q. Complainant alleges in Count XII of her Second Amended Complaint that DTE Electric did not offer her an informal hearing before or after disconnecting her electric service. Did the Company offer Complainant an informal hearing prior to disconnecting her electric service? A. Yes. All shutoff notices sent by the company inform customers of their hearing rights per Rule of the Michigan Public Service Commission billing practice rules. The 00 Bill as well as the previous shutoff notices provide this notification as shown in Exhibit R-. In 0, the Complainant would not have been advised of her right to request a hearing because there was no electric customer of record at the site and the service was being disconnected due to unauthorized usage.

13 S. ROBINSON Line U-0 0 Q. Complainant alleges in Count IX of the Second Amended Complaint that her service was not timely restored after she requested restoration on February, 0. When was service restored? A. Complainant s attorney initially made a request to restore the electrical service at the meter on February, 0 as evidenced in Exhibit R-0. On the th, the restoration was agreed to by DTE Electric. I then placed an order on February, 0 for electrical service to be reconnected at the pole on the next business day, which was Monday, February, 0. On February, 0, the electric service was restored at the meter. The order was then referred to an overhead crew to be reconnected at the pole. The reconnect at the pole was originally scheduled for the following business day, February rd but was not completed due to a wind storm. On February, 0, the reconnect at the pole was completed and the service was restored, as shown on Exhibit R-. On February, 0 service was restored, as shown on Exhibit R-. The Complainant s billing for electrical service then resumed until a request was made to disconnect the service out of her name on April, 0. 0 Q. Would you consider a wind storm to be an event outside of DTE Electric s control? A. Yes. Q. Does this complete your supplemental direct testimony? A. Yes, it does.

14 STATE OF MICHIGAN BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION In the matter of the Complaint of CAROL BROOKS against DTE ENERGY COMPANY Case No: U-0 SUPPLEMENTAL EXHIBITS OF SHANNON ROBINSON

16 STATE OF MICHIGAN BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION In the matter of the Complaint of CAROL BROOKS against DTE ENERGY COMPANY Case No: U-0 SUPPLEMENTAL DIRECT TESTIMONY OF JAMES SKOTZKE

17 DTE ELECTRIC COMPANY SUPPLEMENTAL DIRECT TESTIMONY OF JAMES SKOTZKE Q. What is your name and business address? A. James A Skotzke One Energy Plaza, Detroit, MI Q. On whose behalf are you testifying? A. DTE Electric Company ( DTE Electric or the Company Q. Have you previously filed testimony in this Case? A. Yes. I filed direct testimony on June, 0 to address claims made in the Complainant s First Amended Complaint. 0 Q. What is the purpose of your supplemental testimony? A. The purpose of my supplemental direct testimony is to respond to new allegations raised by Complainant in her Second Amended Complaint regarding an alleged delinquent account. 0 Q. Complainant makes allegations in her Second Amended Complaint in Counts III, VII, and X that there was a delinquent account associated with the first floor of the Monica Property that was not in Complainant s name. Is this accurate? A. There is no delinquent account in cases of unauthorized usage. A delinquent account exists when a customer has established service with DTE Electric, is being billed for the service, and has a past due balance. Unauthorized usage is when a customer s service is disconnected and that service is turned back on by someone other than a representative of DTE Electric. In this scenario the occupant is using the utility service, but not being billed for that use. If the customer is not paying for

18 J. SKOTZKE Line U-0 the unauthorized electric use then no billing is done, therefore a bill is not produced and there is no delinquent bill or account. 0 Q. Complainant alleges that she disputed an alleged bill prior to her January, 0 shutoff. Was there a bill to dispute? A. Again, because there is no person associated with the account in cases of unauthorized usage, there is no delinquent account and, therefore, there is no bill. If an occupant is determined to be responsible for unauthorized electric usage and commits to pay for that usage, the Energy Resolution department does bill the customer for that usage and a bill would be produced. If the customer is not paying for the unauthorized usage then a bill is not produced. Q. Does this complete your supplemental direct testimony? A. Yes, it does. JS -

19 STATE OF MICHIGAN BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION In the matter of the complaint of CAROL BROOKS against DTE ENERGY COMPANY Case U-0 STATE OF MICHIGAN ss COUNTY OF WAYNE PROOF OF SERVICE LORRI A. HANNER, being duly sworn, deposes and says that on the st day of October, 0, a copy of the DTE Electric Company s Supplemental Direct Testimony of Witnesses, Ebony Reid, Joanna Adkins, Shannon Robinson and James Skotzke and Supplemental Direct Exhibit of Shannon Robinson, was served upon the persons on the attached service list via electronic mail. LORRI A. HANNER Subscribed and sworn to before me this st day of October, 0. Karyn B. Kazyaka, Notary Public Macomb County, Michigan My Commission Expires: --0 Acting in Wayne County, Michigan

20 U-0 CAROL BROOKS v DTE ENERGY COMPANY SERVICE LIST Sharon Feldman Administrative Law Judge MAHS/State of Michigan 0 W Saginaw Hwy Lansing, MI -0 feldmans@michigan.gov Michael J. Orris Assistant Attorney General Michigan Dept of Attorney General 0 W Saginaw Hwy Fl. Lansing, MI -0 orrism@michigan.gov Lisa M. Okasinski Mark S. Demorest Demorest Law Firm W. Lincoln Avenue, Suite 00 Royal Oak, MI 0 lisa@demolaw.com mark@demolaw.com

May 18, Kavita Kale Executive Secretary Michigan Public Service Commission 7109 West Saginaw Highway Lansing, MI 48917

May 18, Kavita Kale Executive Secretary Michigan Public Service Commission 7109 West Saginaw Highway Lansing, MI 48917 DTE Electric Company One Energy Plaza, 688 WCB Detroit, MI 48226-1279 Andrea Hayden (313) 235-3813 andrea.hayden@dteenergy.com May 18, 2018 Kavita Kale Executive Secretary Michigan Public Service Commission